Implementation Timeline and Access to the Register
The regime was finalised in June 2025 following an extended consultation period. Its implementation was postponed until 1 April 2026 to allow companies time to prepare. From that date, individuals who can demonstrate a “legitimate interest” will be able to request access to information in the beneficial ownership register maintained by the Registrar. Each request will be subject to a non-refundable fee of USD 75.
Conditions for Access Requests
Applicants seeking access must show that the request is connected with investigating, preventing, or detecting money laundering, terrorist financing, or proliferation financing linked to the relevant legal entity. Alternatively, they may demonstrate that one of the entity’s beneficial owners has been convicted of, or is currently being prosecuted for, such offences.
Who Qualifies as a Beneficial Owner
Only individuals who directly or indirectly hold 25% or more ownership interest—or exercise equivalent control—over a BVI business company or limited partnership can be identified in the register. The information that may be disclosed includes the beneficial owner’s full legal name, month and year of birth, nationality, and details of the nature and extent of their interest or control in the entity.
Applying for an Exemption
In anticipation of a high volume of requests, the Registrar has introduced a process allowing beneficial owners to apply for protection of their information. Applications must be submitted through the VIRRGIN online platform by a company’s registered agent or by a law firm acting on behalf of the applicant.
Application Fees and Processing Time
Each beneficial owner must submit an application for exemption, although a single application may cover multiple legal entities linked to the same owner. The application fee is USD 50 per legal entity for up to five entities, with an additional USD 10 for each further entity included. The Registrar is expected to process applications within 12 business days.
Grounds for Requesting an Exemption
Applicants must specify the grounds for requesting an exemption. The acceptable reasons were outlined in policy guidance issued by the BVI Financial Services Ministry in June 2025. One of the most common grounds is the reasonable belief that disclosure could expose the individual or their immediate family to serious risks such as fraud, kidnapping, blackmail, extortion, harassment, intimidation, violence, or similar harm. Exemptions may also be granted where the beneficial ownership information relates to a minor or a person lacking legal capacity.
Additional Special Grounds for Exemption
Additional exemptions may be granted for special reasons, including situations involving sensitive commercial interests (such as protection of trade secrets), disproportionate public exposure, ongoing legal disputes where disclosure could prejudice proceedings, or conflicts with confidentiality obligations under legal or contractual arrangements. The Registrar may also grant exemptions on the grounds of national security or the public interest.
